Accounting for large non-profits and foundations in Luxembourg

In short. Large associations, public-interest ASBLs and foundations fall under the accounting regime for medium-sized enterprises: a full (non-abridged) balance sheet, an abridged profit and loss account and notes. What many miss: they are exempt from the standard chart of accounts (PCN 2020) and from eCDF filing, and they may adapt the standard layouts to their non-commercial activity. The CNC confirmed this in its Q&A 26/038 of July 2026.

Since the end of the transitional period of the law of 7 August 2023, a large association or a Luxembourg foundation must produce genuine annual accounts, to the same standard as a company. One question keeps coming back: must you go through the PCN chart and the eCDF platform like a business, and which balance-sheet layout should you use? The Accounting Standards Commission (CNC) has just settled these points. Here is what it changes in practice for the applicable regime and the filing of accounts; how to adapt the layouts in detail to a non-commercial activity is the subject of a dedicated article.

Who is concerned

Three types of structure fall under this regime: associations classed as "large" under the law of 7 August 2023, associations recognised as being of public interest, and foundations. Public-interest associations follow the large-association regime whatever their size. How an association is classed as small, medium or large, based on headcount, income and total assets, is set out in our article on the accounting obligations of an ASBL since the 2023 law. This article focuses on the regime of the structures that have moved to the fullest form of double-entry accounting.

The medium-sized enterprise regime, in practice

The law refers these organisations to the accounting regime for medium-sized enterprises, that of the amended law of 19 December 2002. In practice, the annual accounts form a whole made up of three documents: the balance sheet, the profit and loss account and the notes.

In other words, a large ASBL or a foundation cannot make do with an abridged balance sheet: it draws up a full one, but benefits from a lighter income statement. It is an intermediate regime, more demanding than that of a small structure, lighter than the full schedule of a large listed company.

Neither PCN nor eCDF: the exemption many overlook

This is the most misunderstood point, and it changes the workload. No provision of the law of 7 August 2023 subjects associations and foundations to the PCN 2020 chart of accounts or to the standardised collection of financial data on the eCDF platform. Accounts are therefore filed with the trade register in the classic format, without going through eCDF and without filing the general trial balance there. The legislator's intent was explicit: not to load non-commercial organisations with the administrative burden designed for commercial businesses. How the chart of accounts they are exempt from works, for companies, is described in our guide to the standard chart of accounts (PCN 2020).

Nothing prevents using the PCN on a voluntary basis, though. Many structures do, because the standard chart comes with a mapping table that lets you draw up the balance sheet and profit and loss account almost automatically. Even then, the eCDF exemption stands: filing remains classic, without the trial balance. And if the organisation prefers an internal chart of accounts over the PCN, it must then document the correspondence between its chart and the balance-sheet and income-statement items. This "mapping", kept at the registered office, notably eases the auditor's work.

Layouts designed for businesses, to be adapted

The standard balance-sheet and profit and loss layouts, set by the Grand-Ducal regulation of 18 December 2015, were designed for commercial businesses: headings such as "net turnover" or "subscribed capital" mean nothing for a structure that lives on membership fees, donations and grants. Because they are exempt from eCDF, large ASBLs, public-interest associations and foundations are not locked into the fixed form used by businesses: they can, and are indeed expected to, adapt these layouts to the nature of their activity, subject to the principle of consistency of methods. How to do it cleanly, item by item and within the permitted limits, is detailed in our dedicated article on adapting the balance sheet and income statement of a non-profit or foundation.

The approved statutory auditor

Large associations and public-interest ASBLs must have their accounts audited by an approved statutory auditor (réviseur d'entreprises agréé). That is a regulated profession, distinct from bookkeeping, and it is a point on which we are clear: Advena is an accounting firm, not an audit firm. We prepare and keep your accounts in the right format, we document the mapping and we hand the auditor a clean, traceable file; the statutory audit itself is the job of the approved auditor you appoint. This candour about what we do and do not do is part of the seriousness you are entitled to expect.

How we keep these books at Advena

We keep your books in the Odoo we set up for your structure: a chart of accounts aligned with the PCN 2020 where useful, balance-sheet and income-statement layouts adapted to a non-commercial activity, and analytic tracking by grant or project to justify the use of funds to a ministry or a municipality. Your accounts read in real time, not eight months after year-end, which matters especially when a funder asks for figures mid-year. Our fixed fee starts from €325 per month for a small structure; for a large association or a foundation subject to a statutory audit, the file is heavier and the fee is reassessed, but always stated up front, with no surprise invoice. The principle is set out in our article on the cost of an accounting firm, and the wider picture in our guide to accounting firms in Luxembourg.

What this article does not settle

Let's be straight. The accounting regime is one thing, the tax treatment another: accounting doctrine does not prejudge tax consequences, and a regular economic activity can, for an association, trigger a liability assessed case by case. Likewise, a complex arrangement, a consolidation or a very large structure go beyond simple bookkeeping. We inform on the framework and keep the books; we point you to the approved auditor and, where needed, to a specialist tax adviser, rather than deciding in their place.

Frequently asked questions

Does a large ASBL have to use the PCN and file through eCDF?

No. The law of 7 August 2023 subjects neither associations nor foundations to the PCN 2020 chart of accounts or to standardised collection on the eCDF platform. Accounts are filed with the trade register in the classic format. The PCN remains usable on a voluntary basis, but without filing the trial balance through eCDF.

Which balance-sheet layout for a public-interest association or a foundation?

The medium-sized enterprise regime applies: a non-abridged balance sheet, an abridged profit and loss account and notes. The non-abridged profit and loss account remains possible on a voluntary basis.

Can you use the PCN on a voluntary basis?

Yes. An association or a foundation may choose the PCN 2020 to benefit from its mapping table to the balance sheet and income statement, while remaining exempt from eCDF: filing stays classic, without the trial balance. If it prefers an internal chart of accounts, it must document the mapping to the layout items.

Does a foundation need an approved statutory auditor?

Large associations and public-interest ASBLs are subject to audit by an approved statutory auditor. The auditor carries out a regulated engagement distinct from bookkeeping: an accounting firm prepares and keeps the accounts, the approved auditor performs the statutory audit.

Since when does this regime apply?

The law of 7 August 2023 came into force on 23 September 2023, with a 24-month transitional period for existing structures. Since 23 September 2025, the regime applies to all associations and foundations concerned, including those set up before 2023.

Further reading

• Adapting the balance sheet and income statement of a non-profit or foundation
• Non-profit accounting in Luxembourg: ASBL obligations under the 2023 law
• The standard chart of accounts in Luxembourg (PCN 2020): a guide
• Filing annual accounts in Luxembourg: deadlines, late fees and preparation
• Accounting firm in Luxembourg: the complete guide for an SME

Why Advena?

We keep the books of associations and foundations as we do for SMEs, in the management tool we deploy ourselves: accounts in the right format, layouts adapted to a non-commercial activity, documented mapping and a file ready for the auditor. A fee stated up front, a named manager, accounts kept up to date at all times. We inform on the rule and keep the books; we point you to the approved auditor and the tax adviser when your situation calls for it, without ever claiming a regulated title we do not hold.

Information current as of 29 July 2026, based on CNC Q&A 26/038 of July 2026, the law of 7 August 2023 on non-profit associations and foundations and the Grand-Ducal regulation of 18 December 2015. The standard layouts are published on the eCDF platform. This article informs and does not replace an analysis of your situation; accounting doctrine does not prejudge tax consequences.